RoHS Certificate
RoHS Certificate (Declaration of Conformity with RoHS) is a fundamental document in the field of electrical and electronic equipment (EEE), which confirms that a product complies with the requirements of the European RoHS Directive (Restriction of Hazardous Substances). This directive restricts the use of selected hazardous substances in EEE and its compliance is a key condition for the legal introduction of a product to the market of the European Union and the Czech Republic. The RoHS Certificate is not issued by an external authority, but is the result of internal conformity assessment and thorough documentation, for which the manufacturer or importer is responsible.
Basic Legal Framework in the Czech Republic
In the Czech legal environment, RoHS is implemented by Government Regulation No. 481/2012 Coll., on the restriction of the use of certain hazardous substances in electrical and electronic equipment, which follows the Act No. 22/1997 Coll., on technical requirements for products. This legislation adopts the European Directive 2011/65/EU (so-called RoHS 2, with later amendments RoHS 3). The obligations apply to manufacturers, importers, authorized representatives and distributors of EEE.
Significance and Purpose of the RoHS Directive
The main objectives of the RoHS Directive and related certificates are:
- Protection of human health and the environment: Minimization of exposure of people and ecosystems to hazardous chemical substances found in EEE.
- Support for recycling and circular economy: Restriction of substances that complicate or prevent safe recycling of electrical waste (WEEE).
- Ensuring worker safety throughout the product lifecycle: From manufacturing through use to disposal and recycling.
RoHS is closely linked to the WEEE Directive (Waste Electrical and Electronic Equipment Directive), which sets rules for the collection, recycling and environmentally sound disposal of EEE.
Scope of Application: Which Products are Subject to RoHS?
The RoHS Directive applies to a wide range of electrical and electronic equipment. In Czech legislation, 11 product categories are defined:
| Category (according to regulation) | Examples of equipment |
|---|---|
| Large household appliances | Refrigerators, washing machines, dishwashers, electric cookers |
| Small household appliances | Vacuum cleaners, irons, toasters, coffee makers |
| IT and telecommunications equipment | Computers, laptops, printers, phones, modems, routers |
| Consumer electronics | Televisions, audio equipment, DVD players, gaming consoles |
| Lighting equipment | LED bulbs, fluorescent tubes, luminaires (except incandescent bulbs) |
| Electrical and electronic tools | Drills, saws, garden tools (not hand-powered) |
| Toys and leisure equipment | Electric toys, trains, sports equipment with electronics |
| Medical devices | Diagnostic devices, monitors, infusion pumps (with exceptions) |
| Monitoring and control devices | Smoke detectors, industrial panels, thermostats |
| Vending machines | Beverage machines, snack machines, ticket machines |
| Other EEE | Equipment not falling into the above categories |
Exceptions
There are legal exceptions that define products and applications to which RoHS does not apply, in particular:
- Equipment for military purposes and weapons
- Space technology
- Large stationary industrial machinery
- Active implantable medical devices
- Equipment intended exclusively for research and development (B2B)
The list of exceptions is regularly updated and each exception is time-limited.
Overview of Restricted Substances under RoHS (Annex II, current status)
The RoHS Directive sets maximum permitted concentrations for ten chemical substances in so-called homogeneous materials (the smallest unit that can be mechanically separated):
| Substance | Abbreviation | Limit (% by weight) | Typical use | Main health and environmental risks |
|---|---|---|---|---|
| Lead | Pb | 0.1% | Soldering, alloys, cables | Neurotoxin, nervous system damage |
| Mercury | Hg | 0.1% | Fluorescent tubes, switches, relays | Nervous system damage, toxic |
| Cadmium | Cd | 0.01% | Batteries, pigments, coatings | Carcinogen, toxic to kidneys and bones |
| Hexavalent chromium | Cr6+ | 0.1% | Anticorrosive coatings, pigments | Carcinogen, DNA damage |
| Polybrominated biphenyls | PBBs | 0.1% | Flame retardants in plastics | Persistent pollutant, endocrine disruptor |
| Polybrominated diphenyl ethers | PBDEs | 0.1% | Plastics, textiles, foams | Endocrine disruptor, developmental disruption |
| Bis(2-ethylhexyl) phthalate | DEHP | 0.1% | Plasticizers in PVC, cables | Reproductive toxicity, endocrine disruptor |
| Benzyl butyl phthalate | BBP | 0.1% | PVC, adhesives, floor coverings | Reproductive toxicity |
| Dibutyl phthalate | DBP | 0.1% | PVC, varnishes, printing inks | Reproductive toxicity |
| Diisobutyl phthalate | DIBP | 0.1% | Plasticizer in PVC | Reproductive toxicity |
Always check the current list and updates on the website.
Process of Achieving and Demonstrating RoHS Compliance
RoHS compliance is a systematic process involving several steps:
1. Audit and Supply Chain Management
- Identification of all homogeneous materials in the product.
- Obtaining material declarations, certificates or safety data sheets (SDS) from suppliers.
- Risk assessment of the occurrence of restricted substances in individual parts.
2. Testing and Analysis
Most commonly used methods:
- X-ray fluorescence spectrometry (XRF): Non-destructive screening for the presence of Pb, Hg, Cd, Cr, Br (for PBBs and PBDEs).
- Laboratory analyses (ICP-MS, GC-MS): Quantitative determination of phthalates and other organic substances.
If the analysis confirms exceeding the limits, the product must not be placed on the market!
3. Creation and Retention of Technical Documentation
- The manufacturer is required to maintain a technical file containing:
- Description of the product and its function
- Test and analysis results
- Material declarations
- Description of manufacturing and control measures
- Risk analysis
Documentation retention period in the Czech Republic:
at least 10 years from the date of placing the product on the market.
4. Issuance of Declaration of Conformity
- Based on the documentation, the manufacturer issues the so-called EU Declaration of Conformity (Declaration of Conformity – DoC).
- This declaration is legally binding and must be available to supervisory authorities.
5. CE Marking
- A product that complies with RoHS (and other relevant directives) may be marked with the CE mark.
- The CE mark is a “passport” to the European market.
Obligations of Manufacturers, Importers and Distributors
| Role | Obligations |
|---|---|
| Manufacturer | Design, manufacture and control of compliant products, maintenance of technical documentation, issuance of DoC, CE marking |
| Importer | Verify that the manufacturer has conducted conformity assessment, ensure availability of DoC, retain documentation |
| Distributor | Act with due diligence, verify that the product is properly marked and has documentation |
Legal and Commercial Consequences of Non-Compliance with RoHS
- Financial penalties: High fines up to hundreds of thousands of CZK for each non-compliant product.
- Product withdrawal from the market: Obligation to immediately withdraw from sale/prohibition of distribution.
- Ban on placing on the market: A product without a valid RoHS certification/DoC must not be sold in the EU.
- Reputational damage: Loss of customer trust, deterioration of market position.
- Possible criminal penalties: In extreme cases, even personal liability of management.
RoHS vs. REACH – Explanation of Differences
In practice, RoHS and REACH are often confused, but their purpose and scope are significantly different:
| Criterion | RoHS | REACH |
|---|---|---|
| Scope | Electrical and electronic equipment | All chemical substances and products |
| Focus | 10 specific substances (Annex II RoHS) | Thousands of substances, including SVHC (Substances of Very High Concern) |
| Nature | Product directive | Chemical directive |
| Obligations | Restriction of use of substances in specific products | Registration, evaluation, authorization and restriction of chemical substances |
| Obligation to communicate in the supply chain | Only for EEE | For all products containing SVHC above 0.1% |
RoHS: “These 10 substances must not be in EEE above the specified limit.”
REACH: “You must safely manage all chemicals you use and inform about SVHC.”
Practical Aspects of Obtaining and Verifying RoHS Certificate
How does RoHS audit proceed?
- Internal audit of materials and components
- Verification of declarations from sub-suppliers
- Sampling and testing of selected parts
- Documentation of results
- Regular review of compliance when there are changes in manufacturing or supply chain
What is the difference between “RoHS certificate” and “RoHS test report”?
- RoHS certificate is a legal declaration of conformity with RoHS requirements.
- RoHS test report is a technical document issued by a laboratory that documents the result of a specific analysis or test of a product.
Who is authorized to issue a RoHS Certificate?
- RoHS certification is issued exclusively the manufacturer or its authorized representative based on verified documentation and tests.
- External certification organizations can provide verification/testing, but legal responsibility always rests with the manufacturer.
Frequently Asked Questions and Answers
Must every product be tested in a laboratory?
Not necessarily. If reliable and verified material declarations from suppliers are available and there is no suspicion of the presence of restricted substances, documentary verification may be sufficient. Testing is mandatory especially for risk components.
How long must RoHS documentation be archived?
In the Czech Republic and EU, at least 10 years from the date of placing the product on the market.
Is RoHS valid only in the EU?
No. Similar regulations have been adopted by other countries (e.g., China, Turkey, South Korea, California in the USA) – it is always necessary to verify local requirements.
What inspections can be expected?
Supervisory authorities conduct random and targeted inspections of documentation and product analysis. Non-compliance can mean immediate product withdrawal and a fine.
The RoHS Certificate is proof that a product meets high standards of health and environmental protection. It is a key element for access to European and many world markets, ensures the legality and competitiveness of products and is also a sign of the manufacturer’s responsibility to customers and the planet.
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